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In Roshcon v Anchor Auto Body Builders, the Supreme Court of Appeal has clarified the issues caused by its previous decision in SARS v NWK Limited.

Now that most applicants who sought amnesty under the Amnesty Act (or, to give it its full name, The Exchange Control Amnesty and Amendment of Taxation Laws Act No. 12 of 2003) have received their amnesty approvals, many will be turning their attention to the tax-efficiency of their offshore structures, which would also be viewed in conjunction with the costs of maintaining them